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ASC Management Archives - Page 7 of 8 - Pinnacle III

Mar 06
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ASC Medical Equipment

Purchasing ASC Medical Equipment Doesn’t Have to Be a Pain

By ASC Development, ASC Management 2 Comments

Purchasing medical equipment for a new surgery center or adding new equipment to your existing ASC can be daunting.  With forethought, however, the task is manageable and can be downright rewarding.  Here are some important considerations to keep in mind.

1. Buy only what you need.

How do you know you what you need?  Communication with your surgeons is key.  Review their preference cards.  Understand the kinds of cases they perform.  Discuss their equipment model and vendor preferences.  This information will arm you to shop wisely and negotiate well. 

If you’re in an existing center and a physician requests new equipment, identify what prompted the request.  Gather information on how the equipment will improve patient care.  Determine if new volume will be generated and understand what types of cases will be served by the equipment.   Calculate the anticipated return on investment.  If you need the equipment for rarely performed cases and it will take five years to recoup the investment, it may make sense to defer the purchase until the situation changes.

2. Negotiate.

It may not be in your ASC’s best interest to accept the first price a vendor provides.   Determine if you have opportunities for discounts based on aggregated purchases.  Is GPO pricing available?  Are there demo models on hand to purchase?  Is there package pricing based on the number of disposables you purchase from the vendor? 

Don’t be afraid to shop around to see if other vendors offer better pricing.  While your surgeon may be partial to a specific vendor, they may be willing to switch to an alternate vendor if cost savings can be realized.   

Be willing to look at refurbished equipment, especially for your workhorse items.  Once refurbished, these items can last another ten years.  Work with reputable refurbishment vendors when considering this option. 

You can also check for used equipment online.  Craigslist and eBay often have great pieces of equipment available.  Sometimes, the price you pay may be worth the additional risk you assume by shopping for these items online.

3. Trial new equipment.

There is an abundance of new technology on the market right now.  Ask your vendors to bring in new equipment for a trial period.  This will allow surgeons to test the equipment to determine if it meets their needs and provides the highest quality of care to their patients. 

It’s important to have facility staff involved in setting up the equipment.  This allows them to familiarize themselves with the equipment prior to its purchase. During the equipment trial, ask the following questions.  What effect does the equipment have on turnover times?  Does it provide any efficiencies?  The answers will aid in your purchasing decision.

4. Review warranty and service contracts.

If the equipment breaks, is it fully replaceable?  Does the vendor provide loaners to meet the facility’s needs while the equipment is out for service?  Does the warranty cover the first year of service?  Does receiving service from an outside vendor void the warranty?  These are all important questions to consider prior to the purchase.

5. Lease, finance, or pay cash?

When considering how to pay for your equipment, determine the life of the equipment.  What is your cash on hand? How much interest will you pay for the lease or loan?  What are the buyout terms at the end of the lease?  Consider both the short- and long-term impact of the purchase.

6. Delivery and installation.

Often, little thought is given to the delivery and installation of the equipment.  The size of your capital purchase dictates how and where delivery occurs.  If you have a loading dock at your center, indicate that on the purchase order.  If you don’t have a loading dock, ensure you specify the need for a liftgate.  You may think whoever is delivering your equipment will bring it inside and place it where you like.  This is not always the case.  If you need inside delivery and placement of your equipment, indicate this on your purchase order so the vendor can provide this information to the delivery company. 

Another consideration is the unpacking and disposal of delivery pallets.  Sometimes the equipment is delivered encased in pallets.  If you require disposal of this material, let the vendor know.  It is often necessary or helpful to ask your vendor to unpack the equipment for you.  This helps prevent any damage to the equipment and identify issues that may have occurred during transit.

7. User Competency.

To ensure employee competency with new equipment, schedule an in-service demo for your staff with the vendor representative.  Develop a competency document that employees sign-off on indicating they understand the correct use and function of the equipment.  Retain these documents in employees’ personnel files.

Making capital purchases is a vital step in your surgery center’s development. Optimize this process to address the ongoing maintenance and long-term sustainability of your facility.  Once you understand the nuances and address the considerations noted above, the process is easier to navigate successfully.

Lisa Austin – Vice President of Facility Development

Mar 02
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CMS Emergency Preparedness Rule

What the CMS Emergency Preparedness Rule Means for ASCs

By ASC Management No Comments

The Final Rule outlining Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers became effective November 15, 2016.  Ambulatory surgery centers (ASCs) are one of 17 providers and supplier types that must comply with and implement all regulations by November 15, 2017.  The purpose of the 186 page rule is to institute national emergency preparedness requirements and increase patient safety during emergencies.  It also establishes a more coordinated response to natural, technological, and human-caused disasters.

ASCs are required to meet the following four core elements for conditions of participation.  There is a fifth element applicable for integrated ASC health systems who elect to participate in a coordinated emergency management program.

Establishing and maintaining an emergency preparedness program that meets the requirements outlined in the rule, include but are not limited to, the following elements:

1. Develop and maintain an Emergency Management/Operations Plan. Review and update annually. The plan must:

a. Be based on and include a documented facility and community-based risk assessment using an all hazards approach.

b. Include strategies for addressing emergency events identified by the risk assessment.

c. Address patient populations served by the plan. This includes, but is not limited to, the type of services the ASC can provide in an emergency and continuity of operations such as delegation of authority and succession plans.

d. Include a process for cooperation and collaboration with local, tribal, regional, state and federal emergency preparedness officials’ efforts to maintain an integrated response during a disaster/emergency. Integration includes documentation of the ASC’s efforts to contact such officials and its participation in collaborative planning efforts.

2. Establish corresponding policies and procedures.

a. Must be based on the emergency plan, risk assessment, and communication plan.

b. Must be reviewed and updated at least annually.

c. Must minimally address the following elements: tracking sheltered or relocated patients and on-duty staff during an emergency, evacuation from the ASC, a means for sheltering in place, a system of medical documentation, the use of volunteers and other staffing strategies, and the role of the ASC in the provision of care and treatment as an alternate care site.

d. Additional specific requirements pertaining to policies and procedures are available in the Federal Register, Vol. 81, No. 180.[1]

3. Communications Plan

a. Must comply with federal and state laws. It needs to be reviewed and updated at least annually and include the seven elements outlined in the rule.  For more information on the seven elements, refer to page 165 via the hyperlink referenced below.

4. Training and Exercise Program

a. Develop a training program based on the emergency plan, risk assessment, policies and procedures, and communication plan. This should include initial and ongoing training on policies and procedures. Your training program should be reviewed and updated at least annually.

b. Maintain documentation of all emergency preparedness training and demonstrate staff knowledge of emergency procedures.

c. Conduct at least two exercises annually. One should be a community-based full scale exercise if possible. The other should be a facility-based full scale or table top exercise.

d. Develop a documented after action report and improvement plan. Implement improvement items identified and maintain documentation of same.

5. Integrated Health Care Systems

a. ASCs in a system containing multiple separately certified health care facilities that elect to have a unified and integrated emergency preparedness program must meet the five elements outlined in the Integrated Health Care Systems section of the rule.

Accreditation Status:

A facility’s accreditation status is a significant factor in determining the burden to an ASC in terms of both the workload and the associated costs required to meet the new CMS requirements.  The final rule calculates anticipated burden hours and cost estimates for each of the four core elements based on accreditation status.  ASCs accredited by the American Osteopathic Association/Healthcare Facilities Accreditation Program (AOA/HFAP) and American Association for Accreditation of Ambulatory Surgery Facilities (AAAASF) currently have minimal emergency preparedness requirements. Therefore, their anticipated burden is higher.  The Joint Commission (TJC) and the Accreditation Association for Ambulatory Health Care (AAAHC) accreditation standards contain more extensive emergency preparedness requirements. Although ASCs with TJC or AAAHC accreditation will likely incur some work to meet the requirements, their anticipated burden is lower than AOR/HFAP and AAAASF accredited facilities.

What are the next steps for your ASC?

  1. Review the section of the Final Rule that pertains to ASCs on pages 77-82 by clicking on the following link: https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf
  2. Schedule an initial meeting to start work on performing a thorough risk assessment (also known as a Hazard Vulnerability Analysis or HVA).
  3. Complete a gap analysis by cross-walking your existing Emergency Management Program with the final CMS rule to identify areas that do not meet the requirements. Your existing Emergency Management Program should include your Emergency Management/Operations Plan, response plans, policies and procedures, as well as your training and exercise program.
  4. Develop relationships with other ASCs and share your work with one another.
  5. Find local and national resources for the Final Rule at cms.gov.
  6. Take advantage of technical resources which can be found at https://asprtracie.hhs.gov/technical-resources. Click on “CMS Emergency Preparedness Rule: Resources at Your Fingertips” and refer to pages 15-16 for plans, tools, templates, and links to other resources.     
  7. Develop a relationship with your local hospital(s), public health agency, and the Office of Emergency Management. This may be accomplished directly and/or through your regional Health Care Coalition.
  8. Health Care Coalitions are currently evolving in Colorado. Contact your local Hospital Emergency Preparedness Coordinator, Local Public Health Agency, or Office of Emergency Management to determine how to get involved in your designated coalition.[2]

Julie Zangari – Emergency Preparedness Coordinator of Peak One Surgery Center

Michaela Halcomb – Administrator of Peak One Surgery Center 

[1] https://www.gpo.gov/fdsys/pkg/FR-2016-09-16/pdf/2016-21404.pdf

[2] A Health Care Coalition resource specific to Colorado is:  https://www.colorado.gov/pacific/cdphe/health-care-coalitions

Feb 28
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ASC Front Office

Creating Financial Accountability with Your ASC Front Office Personnel

By ASC Management No Comments

One of the most challenging aspects of running a surgery center is eliminating claims processing errors and denials.  These issues lead to delays in reimbursement and decreased revenue.  When it comes to claims processing errors and denials, there are several items your front office can control.  ASC administrators can prevent many of these errors by establishing financial benchmarks that track front office performance.  Implementing these benchmarks will demonstrate to your staff how these controllable factors go a long way toward maintaining healthy reimbursement for your ASC.

To accomplish this, ask yourself the following questions:

Are you tracking registration data entry errors that cause claim denials?

An incorrect insurance address, inaccurate insurance provider, forgetting to include the subscriber date of birth (if subscriber is not the patient), and entering the wrong patient ID number create claim denials.

Review data entry errors with personnel responsible for patient registration.  Most patient accounting systems contain audit mechanisms that allow you to track field updates by user. Encouraging staff to methodically enter data, then double-check their work typically improves accuracy.

Are you tracking denials based on no pre-authorization?

Many payers have pre-authorization requirements for various procedures.  If pre-authorizations are completed prior to the date of service, payers will deny the claims.  

Review denials that occur for this reason with your front office staff.  Ask them to determine why pre-authorizations were not obtained to identify process issues.  Most insurance providers outline pre-authorization requirements on their websites.  Ask your staff to access these websites to review pre-authorization requirements.  They can print this information and place it in a resource binder for future reference.  Consider having your team develop a flow sheet identifying your facility’s top CPT codes, top insurance providers, and corresponding pre-authorization requirements.  These tools will be an invaluable resource.

Are you tracking time of service collection of co-pays and deductibles? Have you outlined expected time of service collection goals?

It is now standard practice for ASC front office personnel to collect co-pays and deductibles at the time of service. 

Set goals for upfront collections and track progress towards those goals.  Share monthly reports with your front office to review any co-pays or deductibles that were not collected.  Determine what types of actions, if any, can be implemented to increase time of service collections.  

Are you tracking whether supporting documents needed for claims processing are provided in a timely manner?

Set benchmark due dates on documents such as operative notes, implant invoices (when applicable), and pathology reports.  Track monthly documents that are not available on the due date. 

Work with your staff to determine why set goals are not met and identify how they can reduce the frequency of late documents.

Is your front office routinely receiving updates on insurance changes such as new contracts and sample cards?

When evaluating trends, you may discover failure to achieve established benchmarks ties back to outdated information.

Many payers have comprehensive information on their websites regarding benefits.  They often display sample insurance cards to assist providers with proper identification of patient plans.  Best practice is for your front office to maintain up-to-date payer information in a resource binder (paper or electronic, whichever works best).  If you maintain sample insurance cards on patients you’ve treated in your ASC, be sure to redact patient-specific information to remain HIPAA compliant. 

Set benchmark goals to track the above-mentioned items, then meet monthly with your front office staff to review these measures.  Identify trends. Encourage open discussion regarding benchmarks, errors, and denials, to help your staff understand how their role affects the health of your ASC.  Provide additional training when warranted to create a work environment where your staff can succeed.  Keep them engaged by asking for suggestions on best practices to optimize their efforts.  Celebrate their successes and enjoy watching your ASC thrive!

Kelli McMahan – Vice President of Operations

Feb 14
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surgeon recruiting

Become A Surgeon Recruiting Master for Your ASC with these Sales Tips

By ASC Management, Leadership No Comments

The recruitment of new physicians to an existing ASC is an essential component of surgery center management. Most ASC administrators are not trained sales/marketing professionals, nor are they supported by a sales force. Here are some tips I have found helpful as I’ve become self-trained in this area over the years.

Identifying potential new surgeons

  • Determine if they meet the criteria your board of managers has established for physicians in your center. Please see my previous blog post for a list of criteria to consider in vetting new surgeons.
  • Be aware of new surgeons moving to your area. Ask your current physicians and the manufacturer representatives who frequently visit your facility to alert you when new doctors enter your market.  Periodically review the list of newly licensed physicians who have recently moved to your area.
  • If your ASC is in a joint venture relationship with a hospital or health care system, work closely with their business development, marketing, or physician liaison team to identify prospects.
  • Target physicians who are unhappy at their current center. Disgruntled physicians oftentimes express their dissatisfaction in their current center’s ORs, hospital ORs, or hospital locker rooms.  You can often garner this information from the representatives mentioned previously, your existing surgeons, or your anesthesiologists who encounter them in these environments.

Setting yourself up for success

Once you have identified a single physician or a group of physicians as prospects, it’s time for the sale. Don’t be afraid of that word.   We’ve all engaged in sales.  At the very least, you sold yourself to your employer to secure your job.  Selling your facility is not that different.  Forge ahead – call the physician’s office and arrange a time to meet with them.

  • Determine what your objective is for the meeting. Is it getting the physician to the ASC for a tour?  Or securing the physician’s agreement to complete a credentialing packet?
  • Research your prospect to learn anything you can about them. Where did they go to school? Where did they train?  What procedures do they perform?  Do they have any dislikes?  If so, what are they?
  • Identify your needs and anticipate their wants. For example, you know you want them at your center, but can you accommodate their preferred day and time.  Determine how to deal with these kinds of scenarios ahead of time and be prepared to present options.
  • Determine what information you need to bring to the meeting. If you have specific information regarding a program you offer, bring that with you to present if afforded the opportunity.  When you have someone on your team who knows a lot about the surgeon’s specialty and will assist in closing the deal, bring them with you.
  • Know your competition. What will other centers be able to offer them?  What were they unhappy about elsewhere?  Prepare to address these topics in a subtle way.
  • Be aware of any previous history between this physician and your facility, or any stakeholders in your facility. Prepare to address these issues.
  • Think win-win. You must bring value to your facility, the physician, and the physician’s scheduler(s).  A one-sided relationship will never work.

Delivering what you promised

Let’s say you’ve identified your prospective surgeon(s) and had a successful meeting with them.  You were so successful, in fact, they are now scheduling cases at your center.  Now you need to ensure your team delivers what you promised.

  • Educate and empower your staff. Brief your staff on the physician’s expectations and what you promised.  Perform a dry run of the surgeon’s cases if you think it will assist the staff provide outstanding customer service.
  • Ensure the physician’s preference cards are correct and everything needed is present, including properly sized scrubs and gloves.
  • Make sure you are in the facility as the physician arrives for their first day. Welcome them, thank them for being there, and follow up with them at the end of the day. These are best practices to maintain for all your doctors every single day.
  • Attempt to schedule them with a consistent team.
  • Communicate, communicate, communicate!

Winning over the schedulers

Lastly, when recruiting new surgeons to your ASC, avoid underestimating the power of their scheduler(s).  I’ve been in many surgeon’s offices where the scheduler determines where their surgeon will perform a case.  I’ve spoken with numerous surgeons who’ve told me they go where their scheduler tells them to go. You must win their schedulers over!

What do schedulers want?

  • The path of least resistance. A full offering of managed care plans allows them to readily determine what procedures and/or surgeries can be performed at the center. And, if the physician has a set block time available, it’s easier for the scheduler to offer specific days to their patients.
  • We all want to do business with people we trust and like. Schedulers are no different.  They like people with “can do” attitudes.
  • They want to schedule at the time they call. Oftentimes the patient is standing there when they are making appointments.
  • They do not want to be put on hold. If this is unavoidable, ensure the hold time is short.
  • Little to no paperwork. We need information from the physician’s office but the process for exchanging information should be streamlined.

The best advice in recruiting new surgeons is to maintain open lines of communication among all parties.  This allows you to capture wants, needs, and dislikes.  Once you have this information, you can work toward creating a situation that satisfies everyone’s needs.  Your surgery center will be the preferred place of choice and you’ll be happy you created this environment from day one.

Robert Carrera – President/CEO

Jan 17
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CMS Survey

An ASC Administrator’s Guide to Responding to a CMS Survey & Plan of Correction

By ASC Management No Comments

At some point, most facilities undergo a Centers for Medicare and Medicaid (CMS) Survey. These unannounced surveys can occur on any given day; hopefully your ASC is ready!

Prepare for Your Survey – Know the Conditions of Coverage

CMS establishes minimum health and safety standards, called Conditions for Coverage (CfCs), that ASCs must meet to obtain and maintain certification. The standards cover all aspects of an ASC from operational organization – including patient care and safety – to facility design. CfCs must be met for all patients seen in your facility, not just those covered by Medicare and Medicaid. You can find these standards in Appendix I: Survey Procedures and Interpretive Guidelines for Life Safety Code Surveys[1] and Appendix L: Interpretive Guidelines for ASCs[2] of the CMS State Operations Manual.

It is imperative for all members of your facility to be familiar with and understand these standards prior to a survey. To ensure sufficient preparation for an unannounced survey, put together binders of all the documentation the surveyors will want to review – policies, contracts, and other agreements – that address each CfC. Include an index that references back to each standard. These binders can then serve as survey preparation for your staff. As staff review each standard and locate the documentation supporting the standard, they are also educating themselves. Remember, the more educated and prepared your facility is, the higher the likelihood that you will achieve a satisfactory survey outcome.

What to Expect When Your Surveyor Arrives

Surveyors usually arrive early in the morning for unannounced surveys. You can plan on them conducting their on-site review for one and a half days to two full days depending on the size of your facility. They will review all aspects of your clinical and business operations. The surveyors will ask to review a multitude of items and one of them will follow a patient through the entire treatment process. The Life Safety surveyor will focus on the building and Life Safety Codes.

Although aiming for a perfect score, even the most highly functioning ASCs are typically cited for something. That’s the nature of the beast. Surveyors, intent on ensuring safety and quality of care for patients and staff alike, seek strict adherence to their certification standards. Deficiencies cited, no matter how minor, prompt a Plan of Correction. 

Upon completion of your survey, you will receive a report via certified mail. The report, which usually arrives within a few weeks of your survey, will include a request for a Plan of Correction (POC). The POC outlines any deficiencies cited during the survey. The deficiencies are reported on CMS-2567.[3] You must respond to each deficiency with specific details pertaining to the corrective actions you plan to take to fully resolve the citation. Your responses are recorded on the right side of the form.

Components of Your Plan of Correction (POC)

Five main components need to be included in your POC:

  1. The first component is the deficiency standard number and a detailed statement of what needs to be corrected. This should be a concise sentence related to the shortcoming.

If you are cited for expired medications in your inventory, for example, your response could be: Q181. The entire medication supply will be monitored monthly for expiration dates.

  1. Next, specify how the deficiency will be corrected. Note detailed information about the corrective action taken and who was involved. List all the items you completed to correct the inadequacy and maintain documentation regarding how you addressed the issue.

For example: Performed staff training on 12/12/2016. All clinical personnel were in attendance. Reviewed policy on expiration of medications and solutions. Revised policy to clarify preference for single dose vials and ampules. Responded to questions from staff regarding who retains responsibility for monitoring medication expiration dates.

  1. The third component notes how you will ensure ongoing compliance with the corrected deficiency – via random audits, for example. If you do audit, retain documentation of audit results. Be specific about how you will monitor the corrections made. Ensure monitoring is consistent and timely. Clearly state how you will maintain compliance.

For example: Updated emergency cart medication lists. Began actively monitoring the expiration dates of all medications throughout the facility. Implemented random audits of the medication supply to ensure compliance. Initial audit was conducted on 12/16/2016 in various locations around the facility. No expired medications were found. Compliance expectation is 100% removal of expired medications from floor stock as evidenced by monthly inspections.

  1. Name the responsible party for completion of each task and ensure ongoing compliance. You are permitted to use a person’s name but noting someone’s title (e.g., Clinical Director or Business Office Manager) ensures responsibility is linked to a defined role rather than a specific individual.
  1. The final component is provision of a completion date for the deficiency. Ensure the deficiency is corrected by the date you set.

Next Steps

Upon completion of the plan, sign and date the form. Return the document to the person and address noted on the Plan of Correction. You typically have 10 days after receipt of the POC letter to return your response.

Make sure you retain a copy of the POC on file at the center with all your corrective action documentation. As you work through the POC and collect supporting documentation, keep everything together in one binder. This is very helpful in the event of a re-survey.

The CMS regional office will review your POC. You can then expect a response letter from them regarding acceptance or denial of your plan of correction. If your POC was accepted, the letter will also inform you whether a re-survey will occur. A rejected POC will contain information regarding any changes that need to be made and a new deadline for completion. Update the POC and return per the letter’s instructions by the specified due date.

Conclusion

Although preparing, undergoing, and responding to a survey is a daunting task, surveys provide us with opportunities to view our ASC operations from the outside in. They allow us to implement best practices that ultimately lead to a center of excellence, a goal we are all trying to achieve. Don’t let the prospect of an unannounced survey worry you. Preparation and organization is key to successfully completing your survey, even if you are required to submit a plan of correction.

Kelli McMahan – Vice President of Operations

[1] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/som107ap_i_lsc.pdf

[2] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107ap_l_ambulatory.pdf

[3] https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS2567.pdf

Jan 17
Love0
CMS Survey

An ASC Administrator’s Guide to Responding to a CMS Survey & Plan of Correction

By ASC Management No Comments

At some point, most facilities undergo a Centers for Medicare and Medicaid (CMS) Survey. These unannounced surveys can occur on any given day; hopefully your ASC is ready!

Prepare for Your Survey – Know the Conditions of Coverage

CMS establishes minimum health and safety standards, called Conditions for Coverage (CfCs), that ASCs must meet to obtain and maintain certification.  The standards cover all aspects of an ASC from operational organization – including patient care and safety – to facility design.  CfCs must be met for all patients seen in your facility,  not just those covered by Medicare and Medicaid.   You can find these standards in Appendix I:  Survey Procedures and Interpretive Guidelines for Life Safety Code Surveys[1] and Appendix L:  Interpretive Guidelines for ASCs[2] of the CMS State Operations Manual.

It is imperative for all members of your facility to be familiar with and understand these standards prior to a survey.  To ensure sufficient preparation for an unannounced survey, put together binders of all the documentation the surveyors will want to review – policies, contracts, and other agreements – that address each CfC.  Include an index that references back to each standard.  These binders can then serve as survey preparation for your staff.   As staff review each standard and locate the documentation supporting the standard, they are also educating themselves.  Remember, the more educated and prepared your facility is, the higher the likelihood that you will achieve a satisfactory survey outcome. 

What to Expect When Your Surveyor Arrives

Surveyors usually arrive early in the morning for unannounced surveys. You can plan on them conducting their on-site review for one and a half days to two full days depending on the size of your facility. They will review all aspects of your clinical and business operations. The surveyors will ask to review a multitude of items and one of them will follow a patient through the entire treatment process. The Life Safety surveyor will focus on the building and Life Safety Codes. 

Although aiming for a perfect score, even the most highly functioning ASCs are typically cited for something.  That’s the nature of the beast.   Surveyors, intent on ensuring safety and quality of care for patients and staff alike, seek strict adherence to their certification standards.  Deficiencies cited, no matter how “minor,” prompt a Plan of Correction.  

Upon completion of your survey, you will receive a report via certified mail.  The report, which usually arrives within a few weeks of your survey, will include a request for a Plan of Correction (POC).  The POC outlines any deficiencies cited during the survey.  The deficiencies are reported on CMS-2567.[3]  You must respond to each deficiency with specific details pertaining to the corrective actions you plan to take to fully resolve the citation.  Your responses are recorded on the right side of the form. 

Components of Your Plan of Correction (POC)

Five main components need to be included in your POC:

  1. The first component is the deficiency standard number and a detailed statement of what needs to be corrected. This should be a concise sentence related to the shortcoming. 

If you are cited for expired medications in your inventory, for example, your response could be:  Q181. The entire medication supply will be monitored monthly for expiration dates.

  1. Next, specify how the deficiency will be corrected. Note detailed information about the corrective action taken and who was involved.  List all the items you completed to correct the inadequacy and maintain documentation regarding how you addressed the issue. 

For example:  Performed staff training on 12/12/2016.  All clinical personnel were in attendance.  Reviewed policy on expiration of medications and solutions.  Revised policy to clarify preference for single dose vials and ampules.  Responded to questions from staff regarding who retains responsibility for monitoring medication expiration dates.

  1. The third component notes how you will ensure ongoing compliance with the corrected deficiency – via random audits, for example. If you do audit, retain documentation of audit results.  Be specific about how you will monitor the corrections made.  Ensure monitoring is consistent and timely.  Clearly state how you will maintain compliance.

For example:  Updated emergency cart medication lists.  Began actively monitoring the expiration dates of all medications throughout the facility. Implemented random audits of the medication supply to ensure compliance. Initial audit was conducted on 12/16/2016 in various locations around the facility.  No expired medications were found. Compliance expectation is 100% removal of expired medications from floor stock as evidenced by monthly inspections.

  1. Name the responsible party for completion of each task and ensure ongoing compliance. You are permitted to use a person’s name but noting someone’s title (e.g., Clinical Director or Business Office Manager) ensures responsibility is linked to a defined role rather than a specific individual. 
  1. The final component is provision of a completion date for the deficiency. Ensure the deficiency is corrected by the date you set.

Next Steps

Upon completion of the plan, sign and date the form.  Return the document to the person and address noted on the Plan of Correction.  You typically have 10 days after receipt of the POC letter to return your response.

Make sure you retain a copy of the POC on file at the center with all your corrective action documentation.  As you work through the POC and collect supporting documentation, keep everything together in one binder.  This is very helpful in the event of a re-survey.

The CMS regional office will review your POC.  You can then expect a response letter from them regarding acceptance or denial of your plan of correction.  If your POC was accepted, the letter will also inform you whether a re-survey will occur.  A rejected POC will contain information regarding any changes that need to be made and a new deadline for completion.  Update the POC and return per the letter’s instructions by the specified due date.

Conclusion

Although preparing, undergoing, and responding to a survey is a daunting task, surveys provide us with opportunities to view our ASC operations from the outside in.  They allow us to implement best practices that ultimately lead to a center of excellence, a goal we are all trying to achieve.  Don’t let the prospect of an unannounced survey worry you.  Preparation and organization is key to successfully completing your survey, even if you are required to submit a plan of correction.

Kelli McMahan – Vice President of Operations

[1] https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/som107ap_i_lsc.pdf

[2] https://www.cms.gov/Regulationsand-Guidance/Guidance/Manuals/downloads/som107ap_l_ambulatory.pdf

[3] https://www.cms.gov/Medicare/CMS-Forms/CMS-Forms/Downloads/CMS2567.pdf

Dec 30
Love2
Attract Surgeons

How to Retain & Attract Surgeons to Your ASC

By ASC Management, Leadership No Comments

Do you have a favorite store where you enjoy shopping? It may be convenient to your home or office. They always seem to have what you need.  And, when you can’t find something, friendly staff members are readily available to assist you. It may not be the least expensive place, but the service and atmosphere make the extra dollars spent worthwhile.

Think about your favorite restaurant – perhaps the excellent food was the original draw.  But you keep going back because the service and overall feeling you have while you are there adds to your overall enjoyment.  It wins out often despite the multitude of dining options available to you.

Then there’s that shop you use to service your car or bike.  When you call, they always remember you.  When you walk in the door, the owner and staff greet you as if they genuinely care about your business.  They provide you with service options that may not always be the most profitable for them, but may make the most financial sense to you.

When we consider how to retain and attract surgeons to our surgery centers, it is helpful to keep these types of experiences in mind.  I purposely mentioned retain first.   It is much easier and less expensive to keep current business than it is to attract new business.  This is especially true for surgeons in an ASC. Emulate the owners and staff members at your favorite businesses who provide you with the quality customer service you appreciate.  Ensure the actions and attitudes of everyone at your center convey to your physicians their business is valued.

Surgeons use ASCs for a variety of reasons.  Here are six ways you may be able to attract them to your center:

  1. Consistently provide outstanding customer service. One size doesn’t fit all.  Surgeons value different aspects of their customer experience.  They may be drawn to measurable factors – low infection and transfer rates or high patient and physician satisfaction, for example.  Or, it may be as simple as the reliable availability of competent staff, the proper equipment, and necessary supplies.
  2. Save them time. When you save surgeons time, you improve their quality of life.  This can be as simple as your center being near their home or office which reduces time in the car.   On time starts and rapid room turnover times strongly impact surgeon time.  And, if the scheduling process is convenient for physicians and their staff, they are more inclined to use your ASC.
  3. Ensure quality. In today’s healthcare environment, quality should be a given.  When we are asked to revitalize struggling centers, we rarely encounter ASCs providing poor quality of care. Surgeons look for measurable factors when assessing quality – make this information available to them.   They also want to see the high nurse to patient ratios they have come to expect in an ASC.  Lastly, quality usually comes down to perception – is your staff knowledgeable, skilled, and experienced?
  4. Offer extensive managed care participation. Provided you are not an out-of-network center, physicians and their offices do not want to have to choose their site of service based on remembering which center participates with which third party payor. Being able to offer surgeons the full spectrum of managed care plans in your market makes your center a more desirable place to work.
  5. Provide return on investment. Most investors subscribe to a simple formula.  If they are receiving distributions – tangible ROI – they are much more likely to participate.  If distributions are far and few between, investor participation decreases and your ASC has minimal opportunities to recruit new surgeons.  Managing your center in a fiscally responsible way with financial stewardship in mind affords you opportunities to both retain and attract new physicians. 
  6. Add value. Be able to answer the question, “What have you done for me lately?”  Constantly look for ways to add value to the lives and practices of the surgeons who use your ASC.  Focus on the items I’ve outlined above and never rest on your laurels.

Rob Carrera – President and CEO

Nov 23
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Onboarding New Physicians

ASC Management Tip: Successfully Onboarding New Physicians

By ASC Management No Comments

Bringing new physicians onboard can be one of the most exciting and challenging parts of ASC management.  New physicians create opportunities to enhance your center’s initiatives and fuel growth.  Onboarding, however, can present challenges as you orient new physicians while simultaneously managing daily operations.  Despite busy schedules maintaining focus on first impressions is important.  Starting off on the right foot with new physicians is instrumental to establishing lasting relationships for your ASC and physicians alike.  

What can you do to ensure smooth transitions that successfully engage new physicians?  We sat down with Kelli McMahan, VP of Operations for Pinnacle III, for some advice.  Here are her top five tips for successfully onboarding new physicians.

  1. Schedule an introduction & tour: Meet with new physicians before they begin performing procedures at your facility.  Schedule time for them to tour your space.  Introduce physicians to as many staff members, anesthesiologists, and physician partners as possible.  This will help new physicians feel welcome and provide them with friendly faces to turn to or contact should they encounter any issues when they begin work at your ASC.  New physicians may also wish to review available instrumentation and equipment.  Make sure your clinical nurse manager, instrument technologist, and other staff members who are familiar with the potential needs of your new physicians, are available to answer questions during the tour.  Navigation to the locker room, the Pre-Op/PACU area, or ORs can be challenging for new physicians.  Make sure your new physicians leave the tour feeling comfortable finding their way around your facility.
  1. Provide a physician welcome guide: Provide a welcome packet to new physicians when they initially arrive at your facility.  The packet should contain helpful information to successfully orient physicians to your ASC.  Examples include, but are not limited to, your mission statement and core values, directions to your facility, important contact information, leadership bios, and relevant resources for new medical staff members.  Include medical staff expectations from your medical staff bylaws, as well as information on how to start scheduling cases, access transcription services, obtain pre-op and post-op guidelines, and find resources for their patients.  List your facility’s H&P requirements, block time guidelines, dictation instructions, approved procedures, and managed care relationships.
  1. Collect preference cards: Discuss with new physicians the importance of supplying preference cards that are applicable for all the services they intend to offer at your facility.   Useful preference cards provide detailed information on physician preferences for supplies needed, OR set-up, and block time/clinic time.  Preference cards can typically be obtained from any of the other facilities at which physicians worked prior to your ASC.  Obtaining preference cards early will allow you and your staff ample time to prepare for the new cases and ensure the appropriate supplies are available. 
  1. Arrange a meeting between physician scheduling staff & ASC scheduling staff: Your scheduling staff should plan on meeting with your new physicians’ scheduling teams to review scheduling processes.  Your staff should take contact information, instructions, forms, and patient information packets to these meetings.   They need to engage the new physicians’ staff and ask how they currently process scheduling information to other entities.   Doing so will set the stage for both entities to work together to establish a mutually beneficial process for sharing appropriate information efficiently and securely.
  1. Follow-up with your new recruits: When new physicians arrive for their first day at your surgery center, be available to greet them and answer any questions.  If you are not personally able to meet them on their first day, ensure you appoint a qualified designee to fill in on your behalf.  Speaking with new physicians at the end of their first day will help you address issues that arose and instill confidence in your facility.

By following these tips, you can provide smooth transitions for new physicians joining your ASC.  If physicians are satisfied with their initial interactions with your center, they are more likely to perform cases at your center for many years to come.   Your success with new physicians will create a positive reputation and opportunities for more physicians to join your facility.  Simply put, successfully engaging new physicians helps turn your facility into the center of choice.  Wouldn’t having too many physicians to onboard due to your ASC’s growth be a nice “problem” to have?

Kelli McMahan – Vice President of Operations

Nov 15
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ASC Reimbursement

What Opportunities Can You Leverage to Increase ASC Reimbursement?

By Payor Contracting No Comments

Multiple leverage opportunities are available to increase ASC reimbursement. Two that quickly come to mind are generally applicable across all outpatient surgery centers.  First, always recognize the payor needs you.  Second, the payor community consistently strives to find lower-cost alternatives to their members being served at hospitals.  

The Payor Needs You

The payor needs to provide a comprehensive provider network to its members. Many payors offer their members a site-of-service differential to steer members to the most cost-effective and appropriate care setting.  For example, a payor may only require a co-payment from the member for services provided at an ASC, but the member will be subject to more costly co-insurance provisions if the same service is obtained at a hospital facility.  Therefore, the payor needs your ASC to help them accomplish their goal of securing high quality and cost-effective care at the lowest out-of-pocket cost for their members.

Moving Cases from Hospitals to ASCs

Payors are increasingly looking for additional opportunities to move higher acuity cases from hospitals to ASCs.  Why?  Because the difference in cost to both the patient and the health plan can be three to four times greater at the hospital.  Therefore, if your ASC can entice payors with the cost savings benefit of performing higher acuity cases on their members at your facility, you may be able to create a “leverage opportunity” that can produce greater ASC reimbursement on some of your lower acuity procedures.

For example, many commercial payors have expressed interest in having total joint replacements and high acuity spine cases performed in ASCs because they recognize the opportunity for cost savings.  In some instances, you can increase the leverage opportunity by offering to perform these cases at a predictable cost.  Some payors (self-insured plans in particular) wish to transfer the risk associated with implant variations by agreeing to an all-inclusive facility price for each high-acuity case type that is negotiated.

If your ASC is interested in, or required to, negotiate all-inclusive rates, be sure your data accounts for all variable costs (e.g., staff, supplies, implants) and associated frequency factors before heading to the negotiation table.  This includes a solid understanding of the size, number, and frequency of use for each implant type, along with any extraordinary supplies associated with each case.  And therein lies the rub – many ASCs who want to perform these cases aren’t equipped to negotiate prosperous at-risk arrangements.  To combat this, consider hiring a seasoned negotiator who has successfully secured at-risk arrangements – someone who will recognize and be better equipped to understand all the moving parts.  Alternatively, your ASC would be wise to refrain from performing at-risk cases initially, focusing instead on cases falling under fee-for-service arrangements.  Doing so allows you to assemble the necessary utilization data before attempting to negotiate all-inclusive case rates.

While adding high acuity orthopaedic and spine cases requires a capital outlay for your ASC, the added investment should not be overly detrimental if you’re already performing orthopaedic cases.  In that case, chances are your center already has a good portion of the instrumentation and equipment necessary to perform the higher acuity procedures.  If you are starting from scratch, however, you will want to complete a comprehensive feasibility analysis to demonstrate the costs and benefits of offering total joint replacement and/or spine cases at your facility.

In any case, enticing payors with the possibility of performing higher acuity cases on their members at your ASC could not only create a leverage opportunity, it may also add to the payor’s dependence on your ASC.  This puts you in a strong position to obtain higher ASC reimbursement, something you were seeking all along.

Dan Connolly – Vice President of Payor Relations and Contracting 

Sep 15
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8 Things ASC Board Members Need to Know About Materials Management

By ASC Management No Comments

As an ASC board member, you are tasked with monitoring your ASC’s total operation. This is no simple feat! It can be difficult to know what questions you should be asking to ascertain whether or not your facility is operating as well as it could be. In an effort to help out, we sat down with our VP of Facility Operations, Kelli McMahan, who provided us with some insight into ASC materials management.

  1. What is your ASC’s medical supplies expense as a percent of its net revenue? Ideally, this figure should come in under 20%. If it does not, determine what’s causing it to be so high and act accordingly.
  1. Are all your physicians using the same supplies or are there any outliers? Sometimes one particular physician routinely uses a specific supply that no one else is using. When supplies can be standardized among all physicians, inventory can be reduced. Because many supplies have to be ordered in bulk, only having to stock one type of gloves in four sizes, for example, creates a more streamlined ordering process, minimizes inventory costs, and frees up valuable storage space.
  1. Does your facility use custom packs and review their contents routinely? A custom pack is a procedural pack that incorporates a majority of supplies used 90% of the time for specific types of procedures. Although most ASCs use custom packs, they tend to overlook the importance of reviewing the contents of those packs on a regular basis. When new procedures are implemented and/or supply preferences change, items that were once used frequently from the packs may now be routinely thrown away. Conversely, an item may be opened for every case that isn’t currently included in the pack. Instead of ordering, stocking, and opening this particular item every time, your ASC may be able to save money by adding it to the custom pack. At a minimum, custom packs should be reviewed annually to ensure they address the facility’s current needs.
  1. Does your ASC contract with a GPO (group purchasing organization) to provide the majority of your basic medical supplies? GPOs are able to extend discounted pricing based on their contracts with suppliers. Make sure your distributor knows you are hooked up with a GPO and loads your discounted pricing into their system. Periodically check the invoice pricing against the contract price to ensure your ASC is receiving the benefit of those discounted arrangements.
  1. Are you ordering inventory using the just-in-time methodology? Items that are used routinely should be ordered according to your case volume to avoid overstocking. Standard orders and delivery dates should be set up with your distributor. Knowing your delivery dates helps you manage supplies on hand. It may be better to place smaller orders two to three times a week rather than placing larger bulk orders which can naturally lead to overstocking.
  1. Have preference cards been updated to reflect supplies actually being used? Reviewing preference cards routinely prevents staff, especially those new to your facility, from opening everything that’s reflected on the card without first checking if the supplies being used have changed. In some cases, the physician no longer uses what’s on the card resulting in opened supplies going to waste.
  1. Have deleted items been moved out of inventory? When items need to be removed from inventory, try to recoup some of the expense. Ask your materials manager to see if your vendor will buy those items back from your ASC or trade in unused items for commodities that continue to be stocked. If your vendor isn’t willing to work with you, determine if other ASCs in the area are interested in purchasing your unused inventory. When all else fails, donate the goods to charity as a tax-deductible contribution.
  1. Are you capturing all the current month’s expenses on your financials? Have materials management personnel look at their purchase order accrual log. If they have not received an invoice for an item that has been ordered and received, the expense can be accrued on the current month’s financial statements. Matching your expenses with your income allows you to more accurately identify financial trends and make sound business decisions.

Knowing what questions to ask about your ASC’s materials management practices not only helps determine where money is being spent but provides insight into the total operation. It can serve as a springboard for discussion with your physician investors about supply use and how best to achieve medical supply standardization. It can create efficiencies that optimize your facility’s operations. Having a thorough understanding of best practices is a great first step toward achieving your goal of a prosperous ASC.

Kelli McMahan – Vice President of Operations